7 CFR 246.12 (a): “ Ate Agency Shall Implement EBT Statewide.”
Nutrition Services WIC10A NCAC 43D .0202, .0203, .0703,0707 and .0708Agency:Contact:DHHS/ Division of Public HealthTysha N. GraysWIC Vendor Manager919-707-5765Impact Summary:State government: YesLocal government: YesFederal government: PossibleSubstantial impact: YesAuthority: G.S. 130A-361; 7 C.F.R. 246; 42 U.S.C. 1786;Purpose of Rule ChangeWe are proposing to implement an electronic benefit transfer (EBT) system for the North Carolina WICProgram. Current WIC participants are issued paper food instruments and cash value vouchers that theycan redeem at grocery stores for infant formula and medical nutritionals as well as nutritious foods, fruitsand vegetables. Change in Federal WIC regulations regarding the mode of issuance and redemption offood benefits has necessitated a nationwide shift from a paper-based system to an electronic system. Per7 CFR 246.12 (a): “By October 1, 2020, each State agency shall implement EBT statewide.” As a resultof this requirement detailed in Federal WIC regulations, the North Carolina WIC Program must developand implement an EBT system where WIC participants are issued benefits loaded onto a card which aresubsequently redeemed at a retail grocery store or pharmacy. EBT will be implemented across the state,from October 2017 until May 2018, using a staged rollout methodology and the rules must be amended toaccommodate changes in issuance and redemption of WIC benefits.The funding level for the Women, Infants and Children (WIC) Program would not be changed as a resultof adopting the proposed permanent rule amendments. The level of funding that comes from federalsources to the State would not be altered by these rules, although the level of unused funds the Statereturns to the federal government each year might decrease. The funds passed from the State to the localgovernments for administering the WIC Program would not change.The Department anticipates that issuing food assistance benefits through an electronic system will makeredeeming WIC benefits at the grocery store more flexible and convenient for WIC participants. Makingthe switch from paper vouchers to an EBT card that looks like a credit card may also reduce the externalstigma associated with using food assistance. The electronic system will provide both participants andvendors with up-to-date information on approved foods, minimizing transaction problems in the checkoutline.Furthermore, the Division of Public Health (DPH) anticipates that data tracking will be easier with anelectronic system, improving the efficiency of the program. The agency will be able to better control foodcosts and reduce fraud and abuse of program benefits.As a result of the rule changes, the State would avoid penalizing actions that the federal governmentmight take if the proposed rule changes are not adopted, including corrective action or loss of programfunding.Page 1 of 11
Proposed Rule Changes and Their ImpactThe proposed rule changes perform the following actions:1. Add the following definitions to rule .0202:a. Electronic Benefit Transfer Processorb. Personal Identification number (PIN)c. Point of Sale Terminald. Product Look Up Code (PLU)e. Universal Product Code (UPC)These definitions have been added due to the Federally required implementation of EBT for allstate agencies.2. Add the Physical Address of the Nutrition Services Branch to rule .0203The address has been added to ensure that those interested know where program-relateddocuments can be obtained.3. Establish Policies and Procedures for WIC Program Management Under an EBT System.WIC ParticipantsThe proposed rule change regarding the implementation of EBT in North Carolina would have apositive impact on WIC Program participation by decreasing psychological costs to participants.Use of paper vouchers/coupons at grocery stores has long been a source of stigma for recipientsof public assistance whether that may be the Supplemental Nutrition Assistance Program (SNAPformerly referred to as Food Stamps) or the WIC Program. The stigma was not only external, butinternal. Some participants perceived that they were looked down upon by other shoppers forusing their vouchers/coupons (external stigma) while others felt bad for using the assistance tomeet basic needs (internal stigma) (Manchester and Mumford 2010). This and other factors hasresulted in a decrease in WIC participation nationwide in recent years. North Carolina alsoexperienced a steady decrease.In an EBT system, public assistance benefits are loaded onto a card which is utilized at a store toobtain approved foods. Transaction of WIC benefits using an EBT card would allow participantsto redeem their benefits without other shoppers knowing because the EBT card will look like anyother credit/debit card. This is a positive programmatic change for participants because use of thecard could drastically decrease the external stigma (psychological cost) associated with usingtheir benefitsEBT implementation would also be beneficial to WIC participants in several other ways. First,they would have a choice regarding the quantity of foods they want to purchase at any given time.Currently, the participant must get everything listed on the food instrument at one time if theywant to obtain all the food listed. For example, a participant is issued four food instrumentswhich each contain 2 gallons of milk, 1 container of 64-ounce juice, 1 dozen eggs, 36 ounces ofbreakfast cereal and 16 ounces of whole wheat bread or whole grains. Though the foodinstruments can be redeemed at different times, all the food on each food instrument must bePage 2 of 11
purchased at the same time because once the food instrument is redeemed, the participant cannotget food they chose not to purchase on a later date. This can create a challenge with storage,expiration and consumption. This issue is greatly minimized with EBT. When an EBT system isused, the participant can get what they need (in an approved quantity) from their list of foodsissued on any given date as long as the benefits are still valid. This means that if they were issued2 gallons of milk for the month, they can redeem one gallon on one day and the other gallon onanother day to allow for adequate storage and consumption of the foods obtained.Another benefit to participants is the streamlined shopping experience. North Carolina will beusing a mobile app for smart phones which will let the participants know what items are WICapproved as well as their benefit balances. Should the participant not have a smart phone, theymay also obtain their benefit balance by calling a toll-free phone number to access the interactivevoice response (IVR) system. The approved food information obtained through the app will bethe same information available to retailers. As a result, confusion regarding approved productswill cease. Additionally, for the vendors with integrated cash register systems that accept credit,debit, SNAP and WIC, the participant will no longer need to separate WIC-approved foods fromtheir other purchases. The system will select the WIC-approved items to deduct from theparticipant’s benefit balance based on the UPC code of the food purchased. WIC EBT willeliminate many obstacles participants face during their shopping experience.See the Uncertainties section for a discussion about how these improvements to the programcould affect future enrollment or future food costs for current participants due to changes in foodinstrument use.State AgencyPrior to implementation, retailers need to upgrade their current cash register systems to transactbenefits for WIC participants using EBT cards. This may either necessitate upgrading thesoftware of current multi-function equipment for retailers with integrated systems or obtainingsingle function equipment (stand-beside point of sale terminals) that will be solely used for WICtransactions. Per Federal regulations a state agency cannot impose the cost of EBTimplementation on vendors. Implementation costs will be absorbed by the state agency forexpenses related to implementation. The state agency will provide single function, stand-besideequipment to approximately 20% (400) of the WIC authorized retailers. These retailers aremostly smaller stores. It is likely that the state agency will provide them with one point of saledevice per store. Each device costs 484.50. Therefore, the cost of equipment provided to thesmaller retailers would be approximately 193,800 ( 484.50 X 400). The majority of the largercorporate chains, approximately 1200 stores (60%), already have the software built into theirmulti-function, cash register systems because of implementation of EBT in other states.Therefore, their software will not need to be updated, only deployed. As a result, the provision ofequipment or software to a small number of vendors translates into an insignificant cost for thestate agency.In addition to the WIC Federal administrative grant, the State agency has received grant fundingfrom the USDA to implement EBT that will be utilized to cover additional costs incurred byPage 3 of 11
vendors for software upgrades and/or equipment. The cost to the Federal government equates tothe amount of the grant provided to the state to implement EBT and administrative funding forthe fiscal years 2017-2019. Funding for implementation was provided to the state during Statefiscal year 2016 and is available until State fiscal year 2019. The complete grant allocated forEBT is 5,173,251 for the four-year period while the administrative funding allocated to pay forthe remainder of the implementation is 1,000,364, making the cost to implement the project 6,173,615. Fifty six percent ( 3,437,610) of that cost is payment to the EBT contractor forcoordinating statewide implementation of the new EBT system. The rest of the funding allocatedwill be used for administrative activities/costs necessary to support the project.The administrative and food budgets will not change for local or state governments as the result ofthese rule revisions unless there is truly an increase in participation or benefits redemption. See theUncertainties section regarding the effect of EBT implementation on WIC program participation.This food cost will be paid for by Federal grant dollars allocated to the state as a result of any futureincrease.Time would be required to train staff regarding new screens designed within the MIS system tomanage EBT and new equipment for card and benefit issuance e.g., printers for cards and devicesused to load benefits onto cards. Training for staff will not require a significant amount of time. Itwill be approximately four hours per staff member and will not have a great impact on the clinicflow. There are approximately 950 staff to be trained which will result in a total of 3800 traininghours for all staff across the state. The estimated average annual salary for local agency WIC staffis approximately 40,000 annually ( 19.23 per hour). As a result, the estimated total cost for localstaff training would be 19.23 X 3800 73,074. The estimated average annual salary for a stateemployee that works for the North Carolina WIC Program is approximately 58,000 ( 27.88 perhour). The number of State staff that will need to be trained is 30. The total cost for training statestaff is estimated to be 27.88 X 4 X 30 3,346.15. Total training costs for the state and localstaff is 76,420.15 combined.A major benefit of implementing the EBT rules is to avoid penalizing actions that the federalgovernment might take if the proposed rules were not adopted. Penalizing actions include:a. If a State agency fails to comply with the federal regulation regarding EBTimplementation, the U.S. Department of Agriculture could put the State on a correctiveaction plan. Should a corrective action plan be put in place, administrative time will beexpended addressing the corrective action and ensuring NC is brought into compliance.The Department cannot estimate the exact savings from preventing a corrective actionplan, but wants to preclude this outcome by implementing an EBT system well inadvance of the federal deadline.b. The USDA may refuse to approve the NC WIC State Plan in future years until NorthCarolina fully complies with federal regulations. Refusal to approve the State Planwould be the most severe repercussion and last resort the USDA would employ to ensurethat North Carolina adopts the required federal regulations.WIC program costs total 196,698,261. Although it is not possible to fully quantify the benefitsthat North Carolina residents (including participants and non-participants) receive from thisprogram, studies have demonstrated that WIC improves the health of nutritionally at-risk women,Page 4 of 11
infants, and children, and reduces fetal death and infant mortality1 as well as healthcare costs.Implementing EBT will allow the state to continue to operate the program at a high level ofservice.EBT implementation can ensure the purchase of the appropriate WIC-approved items by WICparticipants. In order for an EBT system to function properly for WIC, a list of authorized foodshas to be uploaded into the cash register system utilized. This list of foods, identified byindividual Universal Product Codes (UPCs), is called the authorized product list (APL). By usingthe APL, the retailer can determine what food is approved to be transacted by the WICparticipant. This will prevent the purchase of non-approved foods or foods improperlysubstituted due to human error and decrease the opportunity for fraud and abuse of Programbenefits. Though this is a benefit to the Program, it cannot be quantified.EBT implementation will also provide the WIC Program with data useful to improve programmanagement and integrity. The data provided includes, but is not limited to, the type, brand, cost,frequency and time of purchase for each food item. Proper analysis can result in improved costcontainment and fraud detection measures that can aid in overall Program administration,including food package changes and improved rebate billing for infant formula. Though staffwill likely analyze data differently which may result in changes to program policies/procedures,time savings cannot be determined.RetailersThe only cost incurred by the retailer would be the time necessary to train their employees onhow to use the EBT system appropriately on new or existing equipment in their store. Retailerswith an integrated cash-register system will need to train their staff on the new procedures thatthey will be using for WIC. As they will already have a system in place for SNAP (food stamps)transactions, training for WIC will not be extensive. The training for vendors with stand-besidedevices should also be very simple. The stand-beside device chosen is a “plug and play” devicewhich is programmed specifically for the vendor by the EBT Contractor prior to shipment and isvery easy to connect. Using the instructions provided with the equipment, a retailer will be able toset up the equipment and quickly train staff, prior to implementation.Retailers will benefit from the implementation of WIC EBT as well. Not only will the time spentin the checkout lane be reduced, allowing for an efficient and accurate transaction, but they willalways know what the authorized products are when they are transacted. As they will be requiredto download the authorized product list at least once every 24 hours, they will always have themost current list in their system, which will eliminate the purchase of incorrect items due tohuman error and decrease the incidence of fraud and abuse of Program benefits by vendors thattry to substitute approved foods for foods that are not authorized for purchase.Another benefit for retailers will be less time processing WIC benefits. There will no longer be aneed to process food instruments and cash value vouchers manually e.g., reviewing them for1Source: psPage 5 of 11
accuracy, batching them for deposit, assessment of those rejected and returned, etc. This willdecrease the cost and time for back office accounting. Transactions will be processed instantlywhich will facilitate quicker payment for WIC benefits redeemed by participants. Though weexpect this positive impact, it cannot be quantified given the diversity in processes, proceduresand Point of Sale systems employed by the different retailers statewide.4. Modification of Minimum Inventory RequirementsThe minimum inventory requirements were modified to: include new minimum stocking requirements for rice, bread, tortillas, tuna and infantfruits and vegetables, remove the requirement for concentrated formula, decrease the requirement for powdered formula and infant cereal, and increase the requirement for skim milk and canned fruits and vegetablesChanges to the food package and shopping patterns necessitated updating the minimum inventoryrequirements to make them more realistic for retailers and participants. For example, WICProgram data shows that the overwhelming majority of North Carolina WIC participants areissued infant formula in the powdered form, thus eliminating the need to have a minimuminventory requirement for concentrated infant formula.Changes to minimum inventory requirements will not have an economic impact because retailgrocery vendors already have the approved foods added on their shelves for purchase for nonWIC customers and to fully transact food instruments or cash-value vouchers for all WICparticipant categories.UncertaintiesChanges in WIC Participation or Food Cost due to EBTAn article entitled Welfare Stigma Due to Public Disapproval2 details the findings of a studyconducted that concluded that EBT implementation would eliminate the external psychologicalcost associated with benefit redemption at the grocery store and increase WIC participation ratesby 23 percent (Manchester and Mumford 2010). This increase could translate into increasedredemption of WIC benefits by current WIC participants in addition to increased enrollment ofthose eligible to receive WIC. Based on the conclusion of the study, the table below illustrates thepotential increase in redemption and enrollment in North Carolina due to EBT implementation.EBT may remove the external stigma associated with benefit redemption at the grocery store,reducing barriers to program participation. However, the research findings on the effect of EBTon enrollment in food benefits programs such as WIC and SNAP are mixed.Page 6 of 11
A recent study of WIC data from five states3 that implemented EBT found no evidence that EBTincreases enrollment.4 DPH considers this to be the lower bounds of the possible enrollmentchange.Between 1997 and 2004, EBT was implemented for SNAP (then called the Food Stamp Programor FSP) in most states, but EBT was not implemented for WIC. Researchers Manchester andMumford examined SNAP participation pre- and post-EBT and estimated that EBT increasedparticipation in SNAP by 30% due to reduced external stigma. 5 Assuming that the WICtransition to EBT occurred at the same time and in a similar manner as the FSP transition to EBT,Manchester and Mumford estimate that implementing EBT for WIC would have increasedparticipation by 23%.DPH interprets these findings with caution due to a number of factors that could impactparticipation and considers 23% to be the upper bounds of the possible enrollment change.Reduced external stigma may have a different effect among the WIC population than the SNAPpopulation because the eligibility requirements and restrictions on the type of food that may bepurchased under SNAP and WIC are different. There may also be variation in results betweenstates. Furthermore, there is not consensus on the effect of EBT on FNS take-up rates. Somestudies find that EBT increased participation, while others find no statistically significant effect.Manchester and Mumford estimate a larger impact on FNS
EBT is 5,173,251 for the four-year period while the administrative funding allocated to pay for the remainder of the implementation is 1,000,364, making the cost to implement the project 6,173,615. Fifty six percent ( 3,437,610) of that cost is payment to the EBT contractor for coordinating statewide implementation of the new EBT system.
WAC (3/27/2017 1:20 PM) [ 1 ] NOT FOR FILING Chapter 246-221 WAC. RADIATION PROTECTION STANDARDS. Last Update: 6/10/16. WAC. 246-221-001 Purpose and scope. 246-221-005 Radiation protection programs. 246-221-010 Occupational dose limits for adults. 246-221-015 Compliance with requirements for summation of external and internal doses. 246-221-020
14 CFR Part 11 . 14 CFR Part 300 . 14 CFR Part 302 . 49 CFR Part 5 . 49 CFR Part 7 . 49 CFR Part 106 . 49 CFR Part 211 . 49 CFR Part 389 . 49 CFR Part 553 . 49 CFR Part 601 . RIN 2105-AE84 . Administrative Rulemaking, Guidance, and Enforcement Procedures . AGENCY: Office of the
the licensee shall follow the applicable requirements in WAC 246-221-270, WAC 246-232-060, chapter 246-246 WAC, and WAC 246-247-080. 25. The licensee must respond in the manner, and within the period, specified to any and all Department correspondence necessary to keep the license and related information current.
37 CFR 1.55 has been filed in the instant patent application; and 3) any U.S. application-as-filed from which benefit is sought in the instant patent application. In accordance with 37 CFR 1.14(c), access may be provided to information concerning the date o f filing this Authorization.File Size: 803KBPage Count: 7Explore furtherApplication Data Sheet 37 CFR 1.76 (Paper Filed .www.formsworkflow.comForm-Fillable PDFs Available USPTOwww.uspto.govJustia :: Application Data Sheet (37 CFR 1.76) :: Official .forms.justia.comDECLARATION (37 CFR 1.63) FOR UTILITY OR DESIGN .www.uspto.gov37 CFR § 1.97 - Filing of information disclosure .www.law.cornell.eduRecommended to you b
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Practicing Place Value Write 246 on the board and have students practice saying it to a partner. Ask students: What would 246 look like written in expanded form? What if we wanted to round 246 to the nearest ten? To the nearest hundred? How many groups of 10 are in 246? (24). How many 1s would be left? (6)
